The SEC recently brought an enforcement action against a partner of a private equity fund manager for allegedly usurping investment opportunities that belonged – under fiduciary duty principles and fund and manager documents – to the manager’s funds.  According to the order in the matter (Order), the manager had robust compliance policies and procedures in place, conducted an internal investigation and self-reported the partner’s alleged bad acts to the SEC.  The Enforcement Division brought an action against the partner, but did not name the firm itself in the action.  From the perspective of the manager, the fact that it was not named is a good thing, but the fact of the action itself is a bad thing.  For other private fund managers contemplating self-reporting, the important question raised by this matter is the extent to which self-reporting dissuaded the SEC from charging the manager in addition to the partner.  In an effort to answer that question – or at least to refine and particularize it – this article describes the factual and legal allegations in the Order, then discusses the implications of the matter for hedge and private equity fund managers.